Margaret vs. George Brown, William Dallam
View original image: Page  001
[missing figure]

To the Honourable the Judge of the St Louis CircuitCircuit Court
CourtCircuit Court . This petition of MargaretMargaret , HenryHenry â SallySally ,
persons of colour, represents to your Honour, that
they, as they belive are entitled to their freedom on
the following grounds: theirmotherJaneJane was formerly
the slave of Col.Dallam of MarylandMaryland and by
him taken to the State ofKentucky KentuckyKentuckyâ where
she resided untill a fewyears since, and where your
your petitioners were born, that her
master removed her from MarylandMaryland he informed
her that he had manummitted her, such
manummissions to take effect at a future
time, and that said time had elapsed before your
petitioners were born; your petitioners say
that they are informed â believe that said
manummission of their matter was by deed
and that the deed is now of record in the proper
office in the state of MarylandMaryland, which can be
obtained. They also state that some time after
the arrival of their mother in KentuckyKentucky she
was by her said master actually freed â discharged
from all service â obedience, he giving her
complete â perfect personal liberty and power
to do with her self what she pleased, and requiring
from her neither service or wages for her time.
That from that time until the time of her masters
death a period from ten to fifteen years she
lived as a free person with the consent of her
master as aforesaid in the same town or neighborhood
with him. That they your petitioners
were with their mother, brought to St LouisSt Louis by
a son of their old master Cal Dallam namely
WilliamWilliam DallamDallam , who afterwards went to KentuckyKentucky

View original image: Page  002
[missing figure]
and that they are now claimed by him as his slaves
and that said DallamDallam by his agents have been and
now are making preparations to carry off your
petitioners to the South beyond the reach of
assistance â where it will be impossible for
them to assert their right to freedom your petitioner
say that they are all imfants under twenty
one years- they therefore pray that they may
severally be permitted to sue as poor persons
by their next friend George BrownGeorge Brown , and that
your honour will assign them counsel for
to prosecute their suits for freedom- And as
your honour has already authorized their
said mother to sue for her freedom, your petitioners pray your honour to grant them
the same privilege in which case they believe
they will be able to establish their right to
freedom â your petitioners will pray etc

HenryHenry
Sally
Margaret
by
their next
friend

George BrownGeorge Brown